We are committed to making our programs and services more accessible to New Yorkers with disabilities. This Proposed Plan outlines our strategy to make improvements over the next five years.
We welcome your feedback! Comments can be submitted online using the form below. For additional ways to comment, see the Notice link above.
One Response
Public Comment on the New York City Department of Veterans’ Services’ Proposed Five-Year Accessibility Plan
Thank you for the opportunity to comment on the New York City Department of Veterans’ Services (DVS) proposed Five-Year Accessibility Plan pursuant to Local Law 12 of 2023.
As a disabled veteran and someone who’s been involved in New York City’s veterans’ community for many years, I appreciate the opportunity to provide public input before this plan is finalized.
Accessibility is not just a legal requirement. It is fundamental to ensuring that every veteran, regardless of disability, can fully access the services, benefits, resources and opportunities available through DVS.
Local Law 12 provides an important opportunity for City agencies not only to identify accessibility efforts, but also to establish a framework for determining whether those efforts are reducing barriers and improving access for people with disabilities.
I appreciate that this draft recognizes the unique accessibility needs of New York City’s veteran community, including veterans living with both visible and invisible disabilities. This veteran-centered approach is an important improvement and provides a stronger foundation for DVS’s accessibility efforts.
The proposed plan addresses many of the areas required under Local Law 12, including physical accessibility, digital accessibility, communication, workplace accommodations, procurement and employee training.
However, the plan places greater emphasis on the actions DVS will take internally than on how veterans will experience measurable improvements as a result.
The central question should be:
How will veterans, their families and the public know that accessibility has improved?
The final plan can be strengthened by placing greater emphasis on measurable outcomes, veterans’ experiences, transparency and accountability.
1. Strengthen the Veteran-Centered Accessibility Strategy
The revised draft takes an important step by recognizing that veterans experience unique accessibility challenges, including service-connected physical, sensory, cognitive and mental health disabilities.
As New York City’s veteran population continues to age, accessibility will become increasingly important in DVS’s ability to fulfill its mission. Many veterans rely on government services during some of the most challenging periods of their lives, and accessibility can determine whether a veteran is able to successfully navigate those services.
The final plan should continue connecting accessibility priorities directly to the experiences of the veterans DVS serves. The goal should be to ensure veterans can successfully access and benefit from DVS programs, services, information and community engagement opportunities, not just accessibility policies that exist on paper.
2. Establish Baseline Data and Measurable Goals
The plan contains numerous commitments to “continue,” “enhance,” and “improve” accessibility. While these commitments are important, the plan provides limited baseline information against which future progress can be measured.
For example, the plan does not identify:
• the number of accommodation requests DVS currently receives;
• response times for providing accommodations;
• the number of accessible public events conducted annually;
• website accessibility benchmarks;
• customer satisfaction among veterans with disabilities; or
• whether requested accommodations were successfully provided.
Without baseline data and clearly identified performance measures, it will be difficult for veterans and the public at large to determine whether accessibility has improved over the next five years.
DVS should establish measurable objectives, implementation timelines and performance indicators that can be evaluated through future annual accessibility progress reports.
3. Continue Expanding the Focus on Invisible Disabilities
The revised draft appropriately acknowledges veterans living with invisible disabilities. The final plan should build upon that foundation by including more specific commitments related to cognitive accessibility, trauma-informed customer service, plain-language communication, simplified forms, and accessible service delivery.
Accessibility extends far beyond physical barriers. Veterans may experience PTSD, traumatic brain injury, anxiety, depression, cognitive impairments, sensory sensitivities or other conditions that affect how they interact with government services. A truly accessible system recognizes that not every barrier is visible.
4. Strengthen Digital Accessibility
DVS increasingly relies on its website, online resources and downloadable documents to connect veterans with services.
The final plan should include commitments to:
• conduct regular (quarterly or bi-annually) website accessibility reviews;
• remediate legacy PDF documents;
• establish a process to ensure new documents are reviewed for accessibility before publication;
• expand plain-language communication;
• incorporate feedback from veterans and family members who rely on assistive technology; and
• publicly report digital accessibility reviews, identified barriers and improvements made.
Digital accessibility is not only about meeting technical standards. It is about ensuring that veterans and their families can easily find, understand, and use the information they need.
5. Integrate Accessibility Throughout DVS Programs and Partnerships
Accessibility should not be viewed as a separate administrative responsibility. It should be incorporated throughout DVS programs and services, including at outreach events, resource fairs, housing assistance, employment initiatives, women veterans programming and other public-facing activities.
Because DVS functions primarily as a connector between veterans and a larger network of government agencies, nonprofit organizations, and community partners, accessibility should extend beyond the Department.
A veteran’s experience with accessibility does not end when DVS makes a referral. Veterans should encounter accessible services throughout the broader network of organizations that support them.
6. Strengthen Accountability and Veteran Feedback
The final plan should identify the individual or office within DVS that is responsible for coordinating accessibility implementation, monitoring progress and ensuring accountability across Department programs.
The plan should also include implementation timelines and measurable outcomes for each major initiative.
In addition, DVS should establish ongoing opportunities for veterans with disabilities to provide feedback through surveys, listening sessions, advisory groups, or other engagement efforts.
Most importantly, DVS should publicly explain how that feedback influences future improvements.
The success of this plan should not be measured only by internal compliance. It should be measured by whether veterans with disabilities experience fewer barriers and greater access to the services they need.
Accessibility is not defined by the number of policies adopted, training conducted, or meetings held. It is measured by whether veterans can independently and successfully access the services and support systems available to them.
7. Provide Additional Context and Strengthen Future Reporting
While this appears to be DVS’s first Five-Year Accessibility Plan prepared under Local Law 12 of 2023, the Department has served New York City’s veterans for more than a decade and has long been subject to federal and local accessibility requirements.
The final plan should also provide additional context regarding accessibility efforts already undertaken, lessons learned and how those experiences shaped the priorities, goals, and implementation strategies outlined in this plan.
DVS should also clarify how future annual accessibility progress reports will measure and communicate progress.
Those reports should go beyond describing activities completed. They should identify measurable outcomes, remaining barriers, and how feedback from veterans with disabilities influenced future improvements.
Transparent reporting will be essential to demonstrate that this plan is improving accessibility in practice and not simply documenting compliance efforts.
Conclusion
Accessibility is an ongoing process rather than a one-time achievement, and this plan provides an opportunity to establish a stronger framework for improving access over the next five years.
DVS has taken an important step by recognizing the unique accessibility needs of New York City’s veterans. The next step is ensuring those commitments are supported by measurable goals, clear accountability, transparent reporting, and meaningful engagement with veterans with disabilities.
If these recommendations are incorporated, the final plan can move beyond a compliance requirement and become a practical tool for improving how veterans experience DVS services.